Malta’s New Individual Tax Programme Rules, 2026

A new legal notice will replace Malta’s four residence-based tax programmes with a single framework from 1 January 2027, with higher entry thresholds, a five-year renewable status, and transitional protection for those who act before 31 December 2026.

One programme instead of four

On the tax side of Maltese residence planning, four programmes have coexisted for over a decade: the Global Residence Programme for non-EU nationals, The Residence Programme for EU, EEA and Swiss nationals, the Malta Retirement Programme for pensioners, and the United Nations Pensions Programme for individuals in receipt of a UN pension. Each offered broadly the same bargain, that of a special tax status charging 15% on foreign income received in Malta, subject to a minimum annual tax, a qualifying property and a set of ongoing conditions. Each tax residence programme sat in its own legal notice, with its own fees and thresholds.

Legal Notice 195 of 2026, published on 14th July 2026 and titled the “Individual Tax Programme Rules, 2026”, brings all four under a single roof. From 1 January 2027, applicants will apply for one of four categories of special tax status within the same framework, these being: (i) global resident status, (ii) EU/EEA/Swiss resident status, (iii) retired pensioner status, or (iv) UN pensioner status. This legal consolidation comes shortly after what Malta did in January 2026 for employment-based incentives, when the Highly Skilled Individuals Rules consolidated the sector-specific 15% schemes for professionals by virtue of Legal Notice 20 of 2026.

What stays the same

The essential architecture of the programmes survives. Beneficiaries will continue to pay tax at 15% on foreign income received in Malta, with double taxation relief available, while foreign income kept outside Malta stays outside the Maltese tax net. Other income (including Maltese-source income) remains taxable at a flat rate of 35%. Applicants must still hold a qualifying property as their primary residence, carry comprehensive health insurance, remain non-domiciled, be represented by an Authorised Registered Mandatary, and avoid spending more than 183 days in any other single jurisdiction in a calendar year. Furthermore, the tests relating to pensioner applicants remain unchanged and, therefore, the pension must be received in Malta and make up at least 75% of chargeable income for retired pensioner status, while UN pensioners must receive at least 40% of their UN pension in Malta, with that pension remaining exempt.

What changes

Amongst the notable changes brought about by the new rules, we note that the entry economics have been moved materially upwards. Some of these changes include:

• Minimum annual tax: €35,000 for global resident and EU/EEA/Swiss resident status (i.e. more than double the €15,000 that applies under the current Global Residence and Residence Programmes). Retired pensioner status carries a €15,000 minimum, whilst UN pensioner status carries a €20,000 minimum on income other than the exempt UN pension.
• Property thresholds: a qualifying purchased property must cost at least €700,000. This reflects an upward revision against €275,000 under the existing programmes (€220,000 in Gozo and the south of Malta). A qualifying rented property must be leased at no less than €14,000 per year, up from €9,600 per year. This means that as from 1 January 2027, one national threshold applies, with no distinction between different parts of the Maltese islands.
• Fees: a single non-refundable application fee of €8,500, replacing the existing differentiated fees.
• A five-year status: special tax status will be granted for five years at a time, renewable at the applicant’s option for further five-year periods against a €2,500 fee, with the rules stating that renewal is not to be unreasonably withheld. Today’s programmes grant a status of indefinite duration, subject to annual conditions.

Why 31 December 2026 matters

The new rules contain a generous transitional provision yet time limited. Any special tax status granted on or before 31 December 2026, and expressly any application received by that date, continues to apply on its existing terms until 31 December 2031.

In practice, an individual who applies under the current Global Residence Programme or The Residence Programme before 31 December 2026 secures the present framework, i.e. the €15,000 minimum tax, existing property thresholds and existing administrative fees. By contrast, an individual who waits until January 2027 will apply under the new legal framework, meaning more than twice the minimum tax and with a substantially higher property commitment.

For anyone already weighing a move to Malta, applying under the existing tax residence programmes before 31 December 2026 might be a better suited option. 

Already a beneficiary? What this means for you

Existing beneficiaries of the four programmes are protected until 31 December 2031 on their current terms. The new rules already establish that property purchased before the rules come into force for less than the new threshold shall nonetheless be considered to be “qualifying owned property” for the purposes of such rules. Beneficiaries should use the coming months and years to review their position rather than react in 2031.

Is a tax residency programme still the right answer?

At a €35,000 minimum tax, the new programme makes sense for individuals remitting substantial foreign income to Malta each year. For many others, ordinary residence in Malta as a non-domiciled individual, taxed on the remittance basis under Malta’s general rules, may deliver a better outcome in some cases. More information about this subject can be found in our published article Malta’s Non-Dom Tax Regime: Why Global Investors and Expats Choose Malta for Tax Efficiency. Whether or not a tax residency programme is suitable for you depends on your income profile, intended remittances into Malta, your family circumstances and your longer-term intentions.

How Taxentra can help

Taxentra is an Authorised Registered Mandatory for Malta’s tax residence programmes. We advise internationally mobile individuals on the choice between programme and ordinary residence, prepare and submit programme applications, and handle the annual compliance that keeps a special tax status in good standing.

If you are considering a move to Malta, or perhaps already hold a special tax status and want to understand what the 2027 framework means for you, please contact us to schedule a call. 

This article is a general summary of Legal Notice 195 of 2026 and is intended for educational purposes only and does not constitute tax advice.